Dennis E. Runkle and Debra A. Runkle - Page 31

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          that Mr. Boykens, a certified public accountant, thought that               
          their “untaxing” idea was “crazy.”                                          
               We find petitioners’ explanations of their “firm belief” not           
          credible.  Mr. Runkle had a paralegal degree and had the                    
          intelligence to research the law and understand the statutes.  He           
          demonstrated this ability at the summons conference when he                 
          explained that he had already researched section 6001 and this              
          section did not require him to file a return.  Petitioners’                 
          actions and correspondence reveal that their belief was not an              
          honest misunderstanding of complex provisions of the Code.                  
          Instead, it reveals they knew they were required to file returns            
          but failed to do so.  Their asserted belief that the tax law                
          should not apply is an insufficient defense to fraud.  See Cheek            
          v. United States, 498 U.S. 192, 205-206 (1991); Niedringhaus v.             
          Commissioner, 99 T.C. at 219.                                               
               8.   Summary of the Badges of Fraud                                    
               Most of the badges of fraud upon which this Court                      
          customarily relies are present in this case.  Petitioners engaged           
          in a pattern of failing to file income tax returns despite having           
          the business acumen and knowledge they had sufficient income to             
          require them to file tax returns.  They filed tax returns for               
          others but not themselves during the years at issue, and they               
          stopped filing tax returns for themselves after more than 20                
          years filing for themselves.  In addition, they deliberately                

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